To fill out an ATA 106 form, pull together the part’s traceability paperwork first, then transfer the identifying information onto the certificate exactly as it appears on those records and on the part itself: seller and buyer details, manufacturer, part and serial numbers, quantity, a condition code that matches the supporting maintenance release, and a signature from someone your company’s quality system has authorized to make quality determinations. The form is a supplier’s attestation about a part’s trace, condition, and last certifying company, not an airworthiness approval, so every entry must be backed by a document on file.
What You Are Actually Certifying
The Aviation Suppliers Association describes the ATA 106 as a form on which “the supplier (such as a distributor, broker, or stockist) attests to the information regarding trace, condition, and last certifying company, among others.”1Aviation Suppliers Association. C of Cs, Beware the Differences It looks similar to an FAA Form 8130-3 or EASA Form 1 in landscape layout, but it carries no FAA regulatory authority. No regulation requires the form, and issuing one does not certify that a part is airworthy or eligible for installation on a type-certificated aircraft. What it does is create a documented chain between you and the part’s history so a buyer’s receiving inspection has something to evaluate.
Knowing this changes how you complete the form. You are not signing off on airworthiness. You are signing off on the accuracy of the trace and condition information, and on the fact that documentation supporting every entry exists in your files and can be produced on audit.
Documentation to Pull Before You Start
Every field on the form has to be backed by a record. Before opening the template, gather the following:
- Origin records tracing the part to an FAA-approved manufacturing source — a production approval holder under a type certificate, production certificate, parts manufacturer approval, or technical standard order authorization. Shipping tickets, invoices, and packing slips from the previous owner help establish this chain.2Federal Aviation Administration. AC 20-62E CHG 1
- Maintenance history. If the part has been overhauled, repaired, or inspected, you need the maintenance release or return-to-service documentation signed by an appropriately certificated person: an FAA Form 8130-3, a repair station work order, or a maintenance record entry meeting 14 CFR 43.9.2Federal Aviation Administration. AC 20-62E CHG 1
- Teardown reports for parts removed from decommissioned aircraft, documenting what was found during disassembly and any modifications.
- Shelf-life data for any part or material with an expiration date.
All of it must be available for audit at any time. FAA Advisory Circular 20-154A cautions that parts lacking “appropriate documentation or other supporting data necessary to show that the regulatory requirements were met” should be segregated from serviceable inventory until their status is resolved, and it warns that a certificate stating “traceability to the manufacturer available upon request” does not by itself establish traceability.3Federal Aviation Administration. AC 20-154A The paper travels with the part.
Completing Each Field
Layouts vary between the official A4A template and non-copyrighted versions distributors use, but the standard fields are the same:
- Seller information: your company’s legal name, address, and contact details.
- Buyer information: the buyer’s name and, where applicable, the purchase order number and contract number tied to the sale.
- Part identification: manufacturer’s part number, serial number (if the part is serialized), and a written description of the component. Copy these from the physical part and cross-check them against your records.
- Manufacturer details: the name and address of the original manufacturer, along with the relevant production approval type where you have it.
- Quantity: the number of units being transferred under this certification.
- Condition code: the standardized abbreviation for the part’s current status (see below).
- Certification statement and signature: the authorized representative signs, prints their name, and dates the form, attesting the information is accurate and supported by documentation on file.
Accuracy is not optional. A wrong part number, a transposed serial number, or a condition code that does not match the maintenance release gives the buyer’s quality team grounds to reject the shipment, and discrepancies invite scrutiny during FAA audits or a suspected unapproved parts investigation.
Choosing the Right Condition Code
The condition code tells the buyer what state the part is in and what maintenance has been performed. The code has to match the supporting paperwork exactly. The standard abbreviations:
- FN (Factory New): came directly from the OEM, has no operating time or cycles, has never been installed, and is within two years of its manufacture date. Should include the manufacturer’s certificate of conformance.
- NE (New): never used, no operating time, but may not have come directly from the OEM. Retains original certificates and trace information.
- NS (New Surplus): never used, but has passed through one or more sellers. May lack original OEM certification but should have a certificate of conformance and trace documentation from the seller.
- OH (Overhauled): refurbished according to the applicable Component Maintenance Manual standards. The most premium condition for used parts.
- SV (Serviceable): inspected and deemed airworthy. Subcategories include Repaired (REP), Function Tested (FT), and Visually Inspected (IN), each reflecting a different depth of evaluation.
- AR (As Removed): in whatever condition it was in when pulled from an aircraft. Not inspected or tested, no airworthiness certification.
- RB (Rebuilt): completely disassembled, inspected, repaired as needed, reassembled, and tested to the same tolerances as a new part.
- MD (Modified): altered from its prior configuration during repair or overhaul. The teardown report should detail what changes were made.
If you mark a part OH but the maintenance release shows only a visual inspection, the buyer’s receiving inspection will catch it. Code AR when that is what the documentation supports; buyers reading AR know additional evaluation is needed before installation, which is the correct signal to send.
Who Can Sign, and What the Signature Means
The signer must be authorized through your company’s quality management system to make quality determinations on behalf of the organization. This is an internal authorization, not a personal credential like an Airframe and Powerplant certificate. Under FAA AC 00-56B, accredited distributors must maintain an “administrative process that identifies and records the qualifications of employees authorized to make quality determinations” and a training system that ensures personnel “properly execute the quality system.”4Federal Aviation Administration. AC 00-56B CHG 1
The signature carries real legal weight. Federal criminal law under 18 U.S.C. § 38 makes it a crime to knowingly falsify a certification concerning an aircraft part. If the false certification involves a part installed in an aircraft, the penalty reaches up to $500,000 in fines and 15 years in prison. If that part causes serious bodily injury, the maximum rises to $1,000,000 and 20 years. If someone dies, the statute allows imprisonment for any term of years up to life. Organizations face fines up to $10,000,000 or $20,000,000 depending on the outcome.5Office of the Law Revision Counsel. 18 U.S. Code 38 – Fraud Involving Aircraft or Space Vehicle Parts in Interstate or Foreign Commerce Sign only what you can substantiate on paper.
Attaching, Delivering, and Retaining the Form
Attach the completed certification to the part during shipment, physically in a document pouch secured to the packaging or electronically through your company’s digital tracking system. The receiving party’s quality control team will compare the form against the physical part and its records on delivery. If the certification is missing or separated from the shipment, expect the part to be quarantined until documentation is resolved.
For record retention, 14 CFR 145.219 requires certificated repair stations to retain maintenance records for at least two years from the date an article was approved for return to service.6eCFR. 14 CFR 145.219 – Recordkeeping Many companies set internal retention periods well beyond that minimum, often seven to ten years, driven by customer contracts, insurance requirements, and the practical reality that parts stay in service for decades. Check your quality manual for the specific period that applies to you. The point is that ATA 106 forms and the supporting traceability records must remain retrievable for audits and safety investigations for as long as your quality system requires.
Electronic Signatures
If your company issues ATA 106 forms electronically, ATA Spec 2000, Chapter 16 establishes the standard for electronic exchange of release documents using XML formatting, and ATA Spec 42 defines the digital certificate profiles and public key infrastructure requirements for aviation. A digital signature under these standards is cryptographically generated data that identifies the signer and confirms the document has not been altered, which is distinct from a scanned image of a handwritten signature. Your quality system should specify which digital signature standard you follow and how the integrity of electronic records is maintained.
Common Reasons Buyers Reject the Form
Before releasing the shipment, run through the checks a receiving inspector will run. FAA AC 20-154A outlines the process, and the recurring red flags are:
- Missing or incomplete documentation. The certification arrives without supporting trace records, or the trace chain has gaps that cannot be bridged back to an approved manufacturer.
- Part number or serial number mismatches. The numbers on the form do not match what is stamped, etched, or labeled on the part.
- Condition code inconsistencies. The form says OH but the accompanying paperwork only supports AR or SV.
- Physical damage or preservation issues. Visual inspection reveals corrosion, damage, or packaging problems that contradict the stated condition.
- Expired shelf life. For materials or parts with shelf-life limitations, the expiration date has passed or is undocumented.
AC 20-154A directs that parts “of questionable nature” should be segregated from serviceable inventory until their status is resolved.3Federal Aviation Administration. AC 20-154A Every one of these rejections is preventable during preparation.
If the Buyer Is Outside the United States
The ATA 106 is primarily a U.S. industry document. In the EASA regulatory system, the OEM Certificate of Conformity is the minimum acceptable traceability document for expendable parts, and an EASA Form 1 is required for return-to-service releases. An ATA 106 alone does not satisfy EASA Part 145 documentation requirements. If you are selling to European operators or repair stations, plan to supplement the ATA 106 with documentation that meets EASA standards, or expect the buyer to evaluate the part under their own EASA-approved procedures before installation.